Tax Executives Institute, Comments on Proposed Regulations Under Sections 6662 and 6664 of the Internal Revenue Code (May 13, 1991); American Bar Association Civil Penalties Task Force of the Section of Taxation, Comments Concerning Proposed Regulations Under Code Sections 6662, 6664 and 6694 of the Internal Revenue Code of 1986
(June 3, 1991); New York State Bar Association Tax Section Committee on Compliance and Penalties, Report on Proposed Regulations Relating to the Accuracy-Related Penalty (September 10, 1991).
The Fund has a Managed Distribution Plan ("Plan") to pay 7% of the Fund's net asset value on an annualized basis including all available investment income, consistent with its primary investment objectives and as required by the Internal Revenue Code of 1986
, as amended.
Proposed regulations to implement section 864(e) of the Internal Revenue Code of 1986
were initially published in the Federal Register on September 11, 1987.
The Internal Revenue Code of 1986
, as amended, provides certain safeguards to the taxpayer with respect to confidential information disclosed to the IRS during an examination.
As a technical matter, however, the term "deficiency" is defined by section 6211 of the Internal Revenue Code of 1986
to apply only to taxes over which the Tax Court has jurisdiction (income, estate, gift, and certain excise taxes).
Under the Internal Revenue Code of 1986
, the Company may carry forward its NOLs in certain circumstances to offset any future earnings that the Company may have.
1)Unless otherwise noted, all references to sections are to sections of the Internal Revenue Code of 1986
, as such section would be amended by the three penalty reform bills.
On March 2, 1989, the Internal Revenue Service issued proposed regulations under sections 89 and 125 of the Internal Revenue Code of 1986
, relating to the nondiscrimination and qualification requirements for certain employee benefit plans.
Code" shall mean the Internal Revenue Code of 1986
of the Arizona Revised Statutes, as amended, in accordance with the terms thereof and in accordance with Section 501(c)(3) of the Internal Revenue Code of 1986
, as amended (the "Code"), is a tax-exempt nonprofit corporation authorized to act as a secondary market and direct lender for Eligible Loans.
1) Section 482 of the Internal Revenue Code of 1986
, as amended by section 1231(d) of the Tax Reform Act, Pub.
1) Unless otherwise indicated, references to sections in this article are to the Internal Revenue Code of 1986
, as amended.